It is a fact that the European Union legal framework does not expressly protect workers who formalize a report regarding a misconduct that occurred at their workplace. Even though some advances in the past years have already been verified, there is still a legislative gap that needs to be fulfilled, in order to guarantee a more effective and consistent scope of protection, and the Proposal for a Directive of the European Parliament and of the Council on the protection of persons reporting on breaches of Union law, of 23.04.2018, as well as the European Parliament legislative resolution of 16.04.2019 on the Proposal for a Directive already mentioned, in a long term, will combat precisely that. In the light of some aspects regulated in both legal documents, this paper aims to analyse the discrepancies between Member States, by comparing the systems in the United Kingdom, France and Portugal
